ML043640280

Proposed Change Number (PCN) 273 Application for Technical Specification Improvement to Eliminate Requirement to Provide Occupational Radiation Exposure Report

ML043640280
Person / Time
Site:	San Onofre
Issue date:	12/27/2004
From:	Nunn D Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PCN 273
Download: ML043640280 (10)

Text

F V SOUTHERN CALIFORNIA EDISOND Dwight E. Nunn Vice President An EDISON INTERNATIONALO Company December 27, 2004 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555

SUBJECT:

San Onofre Nuclear Generating Station, Unit I Docket No. 50-206 Proposed Change Number (PCN) 273 Application for Technical Specification Improvement to Eliminate Requirement to Provide Occupational Radiation Exposure Report Gentlemen:

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Southern California Edison (SCE) is submitting a request for an amendment to the Permanently Defueled Technical Specifications (PDTS) for the San Onofre Nuclear Generating Station (SONGS), Unit 1.

The proposed amendment would delete the PDTS requirement to submit the occupational radiation exposure report. The change is consistent with NRC-approved Revision 1 to Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-369, 'Removal of Monthly Operating Report and Occupational Radiation Exposure Report." The availability of this TS improvement was announced in the Federal Register on June 23, 2004 (69 FR 35067) as part of the consolidated line item improvement process (CLIIP).

SONGS Unit 1 implemented its PDTS in February 1994. Therefore Monthly Operating Reports, as described in TSTF-369, are not applicable to SONGS Unit 1.

Attachment I provides a description of the proposed change and confirmation of applicability. Attachment 2 provides the existing PDTS pages marked-up to show the proposed change. Attachment 3 provides the revised (clean) PDTS pages.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated California State Official.

P.O. Box 128 San Clemente. CA 92674-0128 949-368-1480 kccDoI Fax 949-368-1490

Document Control Desk December 27, 2004 SCE is herewith making a regulatory commitment in Attachment I "Description and Assessment" (6.1.2) to provide information annually to the NRC to support the apportionment of station dose for SONGS Unit 1 (shutdown) and SONGS Units 2 and 3 (operating).

If you should have any questions regarding this submittal, please contact Mr. Jack Rainsberry at (949) 368-7420.

Sincerely, Attachments: 1. Description and Assessment

2. Proposed Permanently Defueled Technical Specification Changes (marked-up)

3. Revised Permanently Defueled Technical Specification Pages cc: B. S. Mallett, Regional Administrator, NRC Region IV, J. C. Shepherd, NRC Project Manager, San Onofre Unit 1 C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 and 3 S. Y. Hsu, Department of Health Sciences, Radiologic Health Branch

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA )

EDISON COMPANY AND SAN DIEGO GAS )

AND ELECTRIC COMPANY for a Class 104b ) Docket No. 50-206 License to Acquire, Possess, and Use )

A Utilization Facility as Part of ) Amendment Application No. 221 Unit No. 1 of the San Onofre Nuclear )

Generating Station )

SOUTHERN CALIFORNIA EDISON COMPANY AND SAN DIEGO GAS AND ELECTRIC COMPANY, pursuant to 10CFR50.90, hereby submit Amendment Application No. 221. This amendment application consists of Proposed Change Number (PCN) 273 to Facility Operating License DPR-13. PCN-273 is a request to delete the requirement to submit occupational radiation exposure reports in Permanently Defueled Technical Specification (PDTS) D6.9.1.2 for San Onofre Nuclear Generating Station, Unit 1. The availability of this PDTS improvement was announced by the Nuclear Regulatory Commission in the Federal Registeron June 23, 2004 (69 FR 35067) as part of the consolidated line item improvement process (CLIIP).

State of California County of San Diego Subscribed and sworn to (or affirmed) before me day of IQ(!*-'e ~ , 2004 By:t Dwight E. Nunn Vice President MARMUE 5 S> AdComma0

• 137547O0 Notary Pubic - Ccfitorno so, Dfo MCOMM. EgresCouty Oct 14 2006I

ATTACHMENT I Description and Assessment

1.0 INTRODUCTION

The proposed License amendment deletes the requirement in Permanently Defueled Technical Specification (PDTS) D6.9.1.2 for an annual report on occupational radiation exposures.

The change is consistent with NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report,"

Revision 1. The availability of this technical specification improvement was announced in the Federal Register on June 23, 2004 (69 FR 35067) as part of the consolidated line item improvement process (CLIIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-369, the proposed PDTS changes include:

PDTS D6.9.1.1 Annual Reports Deleted PDTS D6.9.1.2 Occupational Radiation Exposure Report Deleted Since PDTS D6.9.1.1 is related to PDTS D6.9.1.2, PDTS D6.9.1.1 has been deleted for completeness.

This application involves a site with both operating and shutdown reactors. As addressed in the Notice of Availability for TSTF-369, Southem California Edison (SCE) has included in this application a regulatory commitment to support the NRC need to apportion doses reported under 10 CFR Part 20 to the different categories of reactors at the site.

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published June 23, 2004 (69 FR 35067) and TSTF-369.

Page 1 of 3

5.0 TECHNICAL ANALYSIS

Southern California Edison (SCE) has reviewed the safety evaluation (SE) published on June 23, 2004 (69 FR 35067), as part of the CLIIP Notice of Availability. This verification included a review of the NRC staffs SE and the supporting information provided to support TSTF-369. SCE has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to San Onofre Nuclear Generating Station, Unit I (SONGS 1), and justify this amendment for the incorporation of the changes to the SONGS 1 PDTS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on June 23, 2004 (69 FR 35067) for this TS improvement, SCE is making the following verifications and regulatory commitments:

1. Not applicable to SONGS Unit 1

2. SONGS has both operating and shutdown reactors.

SCE is making a regulatory commitment to provide information to the NRC annually (e.g., with the annual submittal in accordance with 10 CFR 20.2206) to support the apportionment of station dose for SONGS Unit 1 (shutdown) and SONGS Units 2 and 3 (operating). The data will provide the summary distribution of annual whole body doses as presented in Appendix B of NUREG-0713 for operating and shutdown units.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION Southern California Edison (SCE) has reviewed the proposed no significant hazards consideration determination published on June 23, 2004 (69 FR 35067) as part of the CLIIP. SCE has concluded that the proposed determination presented in the notice is applicable to San Onofre Nuclear Generating Station Unit 1, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

Page 2 of 3

8.0 ENVIRONMENTAL EVALUATION Southern California Edison (SCE) has reviewed the environmental evaluation included in the model SE published on June 23, 2004 (69 FR 35067) as part of the CLIIP. SCE has concluded that the staffs findings presented in that evaluation are applicable to San Onofre Nuclear Generating Station Unit 1, and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. Southern California Edison (SCE) is not proposing variations or deviations from the TS changes described in TSTF-369 or the NRC staffs model SE published on June 23, 2004 (69 FR 35067).

10.0 REFERENCES

Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process, published June 23, 2004 (69 FR 35067).

Page 3 of 3

ATTACHMENT 2 Proposed Permanently Defueled Technical Specification Changes Unit I (Mark-Up)

D6.9 REPORTING REQUIREMENTS ROUTINE REPORTS D6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the U. S. Nuclear Regulatory Commission, Attention: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator of the Regional Office of the NRC, unless otherwise noted.

ANNU4 RFR+T D6.9.1.1 Annual reports cavering the activitics of the unit as described below for t*h.rrpvius calandear year shall be submitted by Miarch 21 of each yea-rd>Del et~ed)

D6.9.1.2 Reports required on an annual basis shall include a tabulation of the number of station, utbility and other personnel (inclIuding eantraeters) reeeiving expasures greater than 100 mrm'r and their associated mfan rem exF!!sure eat-oding to wa'rk and ja ucins++,

e.g., operations a.. suryei lance, insevc illspeetian, routine mai mtemancc spcilainternamee (describe maintenance), ttas~te

_fA neh__ prcsig

___ +k n ulhandling). The dese asinettO ; iu duty uctnsmay b.e estimates based an paeket dosimeter TL, il badge measurements. rsmall expasures totalling less than 20 percent of the individual ta tal dase need mat be accaunted far. in the aggregate, at lceast W0 Icrc-n of the total whal e body dose receivYed from exterv;.;1:3 !-es- shall be assigned to specific major work ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT***

D6.9.1.3 The Annual Radiological Environmental Operating Report covering the previous calendar year shall be submitted by May 15 of each year.

The report shall include summaries, interpretation, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in (1) the ODCM and (2)

Sections IV.B.2, IV.B.3, and IV.C of Appendix I to 10 CFR Part 50.

• A single submittal may be made far a multiple unit station. The submitftal shauldA .ZAhi~nP*htbos sectians that are commoln to all units at the sttAnrDel ete)

• • -This tabulation supplemtnts thc reuiements of 10 CFR 2OB.4 Delet1D)

A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

SAN ONOFRE - UNIT 1 D6.9-1 AMENDMENT NO: +59

ATTACHMENT 3 Revised Permanently Defueled Technical Specification Changes Unit I

D6.9 REPORTING REQUIREMENTS ROUTINE REPORTS D6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the U. S. Nuclear Regulatory Commission, Attention: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator of the Regional Office of the NRC, unless otherwise noted.

D6.9.1.1 (Deleted) I D6.9.1.2 (Deleted) I ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT***

D6.9.1.3 The Annual Radiological Environmental Operating Report covering the previous calendar year shall be submitted by May 15 of each year.

The report shall include summaries, interpretation, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in (1) the ODCM and (2)

Sections IV.B.2, IV.B.3, and IV.C of Appendix I to 10 CFR Part 50.

• (Deleted) I

• • (Deleted) I

• • • A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

SAN ONOFRE - UNIT 1 D6 .9-1 AMENDMENT NO: